Thomas Mark Stafford v. Alkermes, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

10 THOMAS MARK STAFFORD and Case No. 2:20-cv-02472-ODW (GJS)

MARY STAFFORD,

[PROPOSED] STIPULATED PROTECTIVE ORDER Plaintiffs,

v.

15 ALKERMES, Inc.; ALKERMES, PLC; 16 ALKERMES PHARMA IRELAND Ltd;

ALKERMES CONTROLLED

THERAPEUTICS, INC. THE CAMDEN

18 CENTER, INC.; AND DOES

THROUGH 100,

19 Defendants. 20 21 22 23 24 25 26 27 1 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production 3 of confidential, proprietary, or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, the parties hereby stipulate to and petition the court 6 to enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to discovery 8 and that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled…